Developments in transfer pricing legislation

Journal
Houlie, J.; Tamir, A.
Israel
International Transfer Pricing Journal 2008 (Volume 15), No. 4
FormatPDF
EUR
40
| USD
45
(VAT excl.)

As a result of the tax reform in 2003, Art. 85A of the Israeli Income Tax Ordinance was enacted, directly addressing the arm's length price for international transactions between related parties. The regulations thereunder generally follow the OECD Guidelines and the main features of the US transfer pricing regulations. The authors consider the application of Art. 85A and its impact on taxpayers.